Bernard A. Kansky - Page 12

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            dated April 22, 2002, petitioner requested reconsideration by                               
            respondent’s Office of Appeals.                                                             
                  On January 9, 2004, respondent sent petitioner a final                                
            determination disallowing petitioner’s request for abatement of                             
            interest for 1987, 1990, 1991.6                                                             
                  In his petition in docket No. 9544-04, petitioner assigns                             
            error as follows to respondent’s refusal of his request for                                 
            abatement of interest:                                                                      
                  1. The IRS Stoneham, MA office wrongfully witheld my                                  
                  records after subpoena for nearly 5 years before                                      
                  returning them to amend/file said returns.                                            
                  2. If timely returned, the 1988 and 1989 losses could                                 
                  have be used to eliminate all taxes for 1987, 1990, and                               
                  1991.                                                                                 
                                                                                                       
                  3. Penalties were assessed unfairly given the                                         
                  extraordinary family circumstances during the period                                  
                  which included death of father (1987); death of mother                                
                  (1989); daughter becoming total disabled for life;                                    
                  4. Associate attempting suicide (April, ‘91)                                          
                  5. 18 year old son - major kidney surgery (emergency)                                 
                  (1989); and                                                                           
                  6. TP being in poor health and under medical care of                                  
                  MGH for multiple medical problems.* (1987-‘91)                                        
                  7.*Also not given full credit for $750. per month POA                                 
                  between 1997-2001.                                                                    




                  6 Although petitioner’s Form 843 requested interest                                   
            abatement for only 1990, it appears that respondent treated                                 
            petitioner’s Form 843 as a request for interest abatement for                               
            1987, 1990, and 1991.                                                                       





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